In  Equity  No, 


United  States  of  America,  Petitioner, 


International  Brotherhood  of  Electrical 
Workers,  Local  Unions  Nos.  9 and  134, 


PETITION1  IN  EQUITY. 


JAMES  H.  WILKEBSON, 

United  States  Attorney , 
Northern  District  of  Illinois. 

GEORGE  W.  WICKER  SHAM, 

Attorney  General. 

JAMES  A.  FOWLER, 

Assistant  to  the  Attorney  General. 


WASHINGTON  : GOVERNMENT  PRINTING  OFFICE  ; 1918 


%%\>m 

Tnftp 


In  the  District  Court  of  the  United  States 
for  the  Northern  District  of  Illinois. 


United  States  of  America, 

Petitioner , 


v. 


International  Brotherhood  of 
Electrical  Workers,  Local  Union  No.  > 
9,  International  Brotherhood  of 
Electrical  Workers,  Local  Union  No. 
134,  et  al., 

Defendants 


In  equity. 


To  the  honorable  the  judges  of  said  United  States  Dis- 
trict Court , in  chancery  sitting: 

Your  orator,  the  United  States  of  America,  by 
James  H.  Wilkerson,  district  attorney  of  the  United 
States  for  the  northern  district  of  Illinois,  under 
£><ihe  direction  of  George  W.  Wickersham,  Attorney 
General  of  the  United  States,  brings  this  bill  of 
complaint  against  the  International  Brotherhood  of 
Electrical  Workers,  Local  Union  No.  9;  the  Inter- 
national Brotherhood  of  Electrical  Workers,  local 
Union  No.  134;  Martin  J.  Healy,  individually  and 
' as  president  of  said  local  Union  No.  9;  Michael  J. 
Boyle,  individually  and  as  president  of  said  local 

75355—13 


2 


Union  No.  134;  William  J.  Sloan,  individually  and 
as  business  agent  of  said  local  Union  No.  9;  W.  N. 
Harris,  E.  M.  Lamie,  J.  J.  Elliott,  W.  Conrad,  E.  D. 
Shanks,  G.  Florian,  W.  Saunders,  H.  Warner,  W. 
Sinclair,  S.  O.  Minor,  A.  V.  Beckner,  F.  S.  Allen, 
H.  Coghill,  M.  O’Day,  J.  C.  Carroll,  jr.,  J.  Gaul, 
Bert  Coghill,  and  Frank  H.  Carroll,  and  thereupon 
your  orator  represents  to  the  court  and  charges  as 
follows: 

First.  That  the  Postal  Telegraph-Cable  Company 
of  Illinois,  hereinafter  called  the  Telegraph-Cable 
Company,  is  a corporation  legally  organized  and 
existing  under  the  laws  of  the  State  of  Illinois  and  is 
a resident  and  citizen  of  said  State  of  Illinois. 

Second.  That  said  International  Brotherhood  of 
Electrical  Workers,  Local  Union  No.  9,  and  said 
International  Brotherhood  of  Electrical  Workers, 
Local  Union  No.  134,  are  voluntary  associations 
formed  and  existing  in  the  county  of  Cook  and  State 
of  Illinois,  and  that  said  Martin  J.  Healy  is  president 
of  said  local  Union  No.  9 and  said  William  J.  Sloan  is 
business  agent  of  said  Local  Union  No.  9,  and  said 
Michael  J.  Boyle  is  president  of  said  Local  Union  No. 
134;  and  that  said  W.  N.  Harris,  E.  M.  Lamie,  J.  J. 
Elliott,  W.  Conrad,  E.  D.  Shanks,  G.  Florian,  W. 
Saunders,  B.  Warner,  W.  Sinclair,  S.  0.  Minor,  A.  V. 
Beckner,  F.  S.  Allen,  H.  Coghill,  M.  O’Day,  J.  C. 
Carroll,  jr.,  J.  Gaul,  Bert  Coghill,  and  Frank  H. 
Carroll  are  officers,  directors,  managers,  agents, 
members,  or  in  the  employ  of  or  acting  as  confederates 


3 


with  the  said  different  local  unions  in  the  unlawful 
acts  hereinafter  complained  of,  and  they  and  each 
of  said  defendants  reside  in  said  city  of  Chicago,  and 
are  citizens  of  the  said  State  of  Illinois. 

Third.  That  the  said  Telegraph-Cable  Company 
was  chartered  and  organized  under  the  laws  of  said 
State  of  Illinois  for  the  purpose  of  constructing, 
maintaining,  and  operating  lines  of  magnetic  tele- 
graph in  said  State,  and  that  upon  such  incorpora- 
tion it  became  a common  carrier  of  telegraph  mes- 
sages and  was  required  under  the  provisions  of  the 
statute  in  that  behalf  made  and  provided  to  receive 
any  telegraphic  dispatch  from  any  other  company  or 
person  tendering  the  same,  and  was  further  made 
subject  to  forfeiture  of  all  right  to  transact  business 
in  said  State  and  might  be  enjoined  in  any  court  of 
competent  jurisdiction  from  transacting  its  said 
business  if  it  refused  or  neglected  to  transmit  mes- 
sages as  aforesaid,  besides  being  held  liable  for  all 
damages  which  should  accrue  by  reason  of  such 
refusal  to  the  company  or  person  offering  such  dis- 
patch for  transmission. 

That  said  Telegraph-Cable  Company  has  been  since 
its  incorporation  and  now  is  duly  carrying  on  the 
business  of  a common  carrier  of  messages  in  said  State 
and  is  now  operating  over  thirteen  thousand  (13,000) 
miles  of  telegraph  wires  in  said  State.  That  said 
lines  of  telegraph  wires  extend  across  said  State  to  the 
boundary  lines  thereof  and  there  connect  with  the 
lines  of  other  telegraph  companies  with  which  the 


4 


above  telegraph  company  has  entered  into  arrange- 
ments for  the  continuous  transmission  of  said  mes- 
sages to  the  destinations  thereof. 

That  said  Telegraph-Cable  Company  is  engaged  in 
interstate  and  foreign  commerce  in  the  transmission 
of  messages  from  points  in  said  State  of  Illinois  over 
its  said  lines  and  the  lines  connecting  therewith  as 
aforesaid  to  points  located  in  other  States  and  in  for- 
eign countries  and  in  receiving  and  transmitting  mes- 
sages sent  from  points  in  such  other  States  and  for- 
eign countries  to  points  in  said  State  of  Illinois  over 
its  said  lines  and  connections  therewith  as  aforesaid. 

Fourth.  That  said  Telegraph-Cable  Company  has 
duly  filed  with  the  Postmaster  General  of  the  United 
States  its  written  acceptance  of  the  restrictions  and 
obligations  of  a certain  act  of  Congress,  approved 
July  24,  1866,  in  which  it  is  provided  that  telegraph 
companies  accepting  the  provisions  thereof,  may 
construct  and  maintain  and  operate  lines  of  telegraph, 
through  and  over  any  portion  of  the  public  domain 
of  the  United  States,  over  and  along  any  of  the  mili- 
tary or  post  roads  of  the  United  States,  and  over, 
under,  or  across  the  navigable  streams  or  waters  of 
the  United  States,  and  that  said  Telegraph-Cable 
Company  is  now  operating,  subject  to  the  terms  of 
said  act  of  Congress  and  by  reason  of  said  act  and  of 
the  amendments  thereto  and  the  act  of  Congress  ap- 
proved March  1,  1884,  has  the  right  to  operate  its 
telegraph  fines  over  public  roads  and  highways,  kept 
up  and  maintained  as  such  throughout  the  United 
States. 


5 


Fifth.  That  said  Telegraph-Cable  Company  is  also 
subject  to  the  provisions  of  the  interstate  commerce 
act  and  the  amendments  thereof  by  reason  of  the 
provisions  of  the  act  of  Congress  approved  June  18, 
1910,  extending  the  jurisdiction  of  the  Interstate 
Commerce  Commission  over  all  telegraph  companies 
engaged  in  the  transmission  of  interstate  messages. 
That  said  Telegraph-Cable  Company  has  an  extensive 
interstate  business  originating  at  and  coming  to  the 
city  of  Chicago,  in  said  State  of  Illinois.  That  in 
said  city  it  daily  receives  or  transmits  interstate 
messages  as  aforesaid  to  the  number  of  approximately 
fifty  thousand. 

Sixth.  That  said  Telegraph-Cable  Company  in 
pursuance  of  the  provisions  of  said  act  of  Congress 
of  July  24,  1866,  receives  or  transmits  at  Chicago  for 
the  Government  of  the  United  States  a large  number 
telegrams  between  the  several  departments  thereof 
and  their  officers  and  agents,  and  gives  them  priority 
over  all  other  business  at  rates  fixed  by  the  Postmas- 
ter General  of  the  United  States,  and  that  said  com- 
pany is  subject  to  the  act  of  Congress  of  June  10, 
1872,  providing  for  severe  penalties  if  any  such  tele- 
graph company  refuse  or  neglect  to  transmit  any 
telegraph  communication  tendered  by  the  officers  of 
the  Government  of  the  United  States. 

Seventh.  That  at  said  city  of  Chicago,  in  the  State 
of  Illinois,  there  are  many  and  divers  great  industrial 
and  commercial  establishments  requiring  for  the 
proper  conduct  of  their  business  prompt  and  con- 
tinuous and  uninterrupted  telegraphic  communica- 


6 


tion  with  points  in  other  States  and  in  foreign  coun- 
tries. 

That  among  said  great  industries  there  located 
are  the  packing -house  industries  of  the  district 
known  as  the  stock  yards  in  said  city  of  Chicago, 
and  that  said  Telegraph-Cable  Company  has  a large 
number  of  telegraph  wires  in  constant  use  in  con- 
nection with  said  packing-house  industries  there  lo- 
cated. That  among  the  other  great  business  inter- 
ests centering  in  the  city  of  Chicago  is  the  buying 
and  selling  of  grain  on  the  Chicago  Board  of  Trade, 
and  that  those  there  engaged  in  said  business  require 
constant  and  uninterrupted  telegraphic  communica- 
tion with  points  in  other  States  and  foreign  countries, 
and  that  said  Telegraph-Cable  Company  has  a large 
number  of  wires  constantly  in  use  during  business 
hours  in  connection  with  said  board  of  trade  and 
the  concerns  there  doing  business.  That  any  inter- 
ference with  the  said  wires  of  said  Telegraph-Cable 
Company  or  with  its  other  telegraphic  lines,  connect- 
ing said  city  of  Chicago  with  points  in  other  States 
and  foreign  countries,  constitutes  an  interference 
with  and  interruption  of  interstate  commerce,  and 
is  greatly  to  the  detriment  of  the  public,  including 
officers  of  the  Government  of  the  United  States,  who 
make  use  of  the  lines  of  said  telegraph  company  for 
the  transmission  of  their  interstate  messages.  That 
without  prompt  and  uninterrupted  telegraphic  com- 
munication between  said  city  of  Chicago  and  points 
in  other  States  and  foreign  countries,  the  sale  and 


7 


shipment  of  products  and  merchandise  in  interstate 
commerce  would  be  seriously  interfered  with  and 
the  efficiency  of  the  different  departments  of  the 
Government  of  the  United  States  would  be  greatly 
impaired. 

Eighth.  That  in  or  about  the  month  of  Septem- 
ber, 1912,  there  arose  between  said  Telegraph-Cable 
Company  and  the  officials  of  said  local  unions  Nos. 
9 and  134,  claiming  to  represent  employees  of  said 
company  who  were  members  of  said  unions,  a dispute 
concerning  the  terms  of  employment.  That  said 
union  officials  insisted  that  contracts  be  executed  by 
said  Telegraph-Cable  Company  with  said  local  unions 
specifically  providing  that  said  Telegraph-Cable  Com- 
pany should  employ  only  such  men  as  were  members 
of  said  unions,  respectively,  in  their  several  lines  of 
work,  thus  establishing  what  is  commonly  known  as 
the  “ closed-shop”  policy  on  the  part  of  said  Tele- 
graph-Cable Company.  That  the  officers  of  said 
Telegraph-Cable  Company  refused  to  agree  to  the 
“ closed-shop”  policy  as  aforesaid,  which  policy  would 
have  necessitated  the  discharge  by  said  Telegraph- 
Cable  Company  of  old  and  faithful  employees  who 
were  not  members  of  said  unions.  That  at  a confer- 
ence with  defendants,  Healy  and  Boyle,  on  or  about 
September  25th,  1912,  the  officers  of  said  Telegraph- 
Cable  Company  asked  said  defendants  what  the 
result  would  be  if  they  refused  to  agree  to  the  terms 
proposed,  and  said  defendants,  or  one  of  them,  then 
replied  in  substance  that  in  that  event  they  would 
call  out  their  men  on  a strike  and  fight  said  Telegraph- 


8 


Cable  Company,  making  it  cost  them  as  much  or 
more  as  recent  trouble  with  the  Western  Union  has 
cost  that  company.  That  thereupon,  said  dispute 
having  reached  an  acute  stage,  where  a strike  on  the 
part  of  said  local  unions  and  their  members  was 
threatened  and  imminent,  said  officers  of  said  Tele- 
graph-Cable Company,  on,  to  wit,  October  15th,  1912, 
discharged  said  employees  who  were  members  of  said 
local  unions  and  supplied  their  places  with  men  who 
were  not  members  of  said  unions. 

Ninth.  That  immediately  thereafter  threats  were 
made  against  officers  and  employees  of  said  Tele- 
graph-Cable Company,  and  acts  of  violence  began  to 
be  committed  daily  and  in  divers  places  in  said  city 
of  Chicago  against  the  property  of  said  Telegraph- 
Cable  Company,  whereby  the  telegraph  lines  of  said 
company  were  cut  or  otherwise  injured  or  destroyed 
by  the  use  of  acids  or  other  means,  thereby  greatly 
interfering  with  and  crippling  the  service  that  said 
Telegraph-Cable  Company  was  able  to  give  to  those 
seeking  to  transmit  messages  in  both  intrastate 
and  interstate  commerce  over  its  lines,  including 
officers  of  the  Government  of  the  United  States, 
whose  messages,  though  given  preference,  as  required 
by  the  acts  of  Congress  aforesaid,  were  still  greatly 
delayed  in  their  transmission  by  reason  of  the 
interference  with  the  wires  of  said  Telegraph-Cable 
Company  above  set  forth. 

Tenth.  That  said  acts  of  depredation  have  been 
repeated  almost  daily  during  the  entire  period  since 
the  discharge  of  said  former  employees  as  aforesaid, 


9 


and  your  orator  believes,  and  therefore  charges  on 
information  and  belief  the  fact  to  be,  that  said  acts 
have  been  performed  by  or  under  the  direction  or  by 
the  connivance  of  said  defendants  Healy  and  Boyle 
and  the  other  defendants  above  named  and  persons 
confederating  with  them,  whose  names  are  to  your 
orator  unknown,  and  that  said  defendants  and  said 
parties,  whose  names  are  to  your  orator  unknown, 
are  unlawfully  conspiring  and  combining  together  to 
injure  the  telegraph  wires  and  lines  of  said  Telegraph- 
Cable  Company  and  to  interfere  with  the  transmission 
of  telegraphic  messages  aforesaid,  both  in  interstate 
and  intrastate  commerce.  Your  orator  further 
charges  the  fact  to  be  that  said  individual  defend- 
ants have  at  all  times  herein  mentioned  well  known 
the  character  of  the  interstate  commerce  business 
conducted  by  said  Telegraph-Cable  Company,  and 
that  in  committing  or  conniving  in  the  commission 
of  the  acts  of  violence  above  set  forth,  they  have 
purposely  and  deliberately  interfered  with  the  trans- 
mission of  the  telegraph  messages  in  interstate  com- 
merce as  aforesaid,  in  violation  of  the  rights  of  said 
Telegraph-Cable  Company  and  of  the  parties  sending 
said  interstate  messages,  which  are  granted  and 
guaranteed  to  them  under  the  Constitution  and  laws 
of  the  United  States. 

Eleventh.  Your  orator  further  shows  unto  your 
honors  that  said  Telegraph-Cable  Company  has  in 
said  city  of  Chicago  some  thirty-five  (35)  miles  of 
telegraph  cables,  each  of  said  cables  containing  a 
large  number  of  its  telegraph  lines  or  wires  coiled 


10 


together  and  encased  in  a lead  covering.  That  a por- 
tion of  said  cables  are  suspended  and  hung  under  the 
elevated  structures  of  the  elevated  railroad  lines  of 
said  city  of  Chicago,  while  other  of  said  cables  are 
located  in  conduits  placed  beneath  the  surface  of  the 
streets,  and  still  others  are  hung  upon  poles  placed 
along  the  sides  of  said  streets.  That  said  cables  con- 
taining the  wires  used  for  the  transmission  of  inter- 
state messages  to  points  in  other  States  extend  out 
into  the  less-thickly  settled  sections  of  Chicago,  and 
that  at  these  points,  as  well  as  at  the  points  where 
the  cables  are  suspended  from  the  elevated  structures 
aforesaid,  they  are  particularly  open  to  attack,  and 
that  it  is  most  difficult  to  adequately  guard  the  same. 
That  since  the  beginning  of  the  labor  troubles  herein- 
before set  forth  said  Telegraph-Cable  Company  has 
employed  a large  number  of  special  officers  and 
guards  to  watch  its  said  cables  and  telegraph  wires 
and  to  prevent  injury  thereto,  but  that  because  of  the 
extent  of  said  cables  and  their  location  aforesaid  said 
Telegraph-Cable  Company  has  been  unable  to  pre- 
vent these  frequently  recurring  acts  of  violence, 
which  are  usually  committed  in  the  night  time,  or  to 
apprehend  and  punish  those  responsible  therefor. 
That  said  acts  of  violence  will,  as  your  orator  is  ad- 
vised and  believes,  continue,  and  that  the  transmis- 
sion by  said  Telegraph-Cable  Company  of  messages 
in  interstate  commerce  and  of  Government  messages 
will  continue  to  be  seriously  interfered  with,  to  the 
great  and  irreparable  injury  both  of  said  Telegraph- 


11 


Cable  Company  and  of  those  using  its  lines  for  the 
transmission  of  messages  as  aforesaid,  unless  relief 
is  afforded  by  this  honorable  court. 

For  as  much,  therefore,  as  your  orator  is  without 
remedy  in  the  premises,  save  in  a court  of  equity, 
and  to  the  end  that  said  defendants  heretofore 
named,  and  each  of  them,  may  be  ordered  to  well, 
true,  and  perfect  answer  make,  to  this,  your  orator’s 
bill  of  complaint,  but  not  under  oath,  their  answer 
under  oath  being  hereby  expressly  waived,  and  that 
said  defendants,  and  each  of  them,  and  all  persons 
now  or  hereafter  conspiring  with,  confederating  with, 
or  acting  in  concert  with  said  defendants,  or  either 
of  them,  or  their  servants  or  agents,  may  be  restrained 
and  enjoined  from  in  any  manner  interfering  with, 
hindering,  obstructing,  or  stopping  any  of  the  busi- 
ness of  said  Telegraph-Cable  Company  in  the  man- 
agement, conduct,  or  operation  of  any  of  its  business 
as  a common  carrier  of  telegraph  messages  between 
or  among  any  States  of  the  United  States,  or  of 
messages  of  the  Government  of  the  United  States  as 
aforesaid,  and  from  in  any  way  or  manner  cutting, 
burning,  tearing,  or  otherwise  injuring,  destroying, 
or  interfering  with  any  of  the  telegraph  lines  or  wires 
of  said  Telegraph-Cable  Company,  engaged  in  inter- 
state commerce  or  transmitting  messages  to  or  from 
States  other  than  Illinois  from  or  into  said  State  of 
Illinois,  or  messages  of  the  Government  as  aforesaid, 
and  from  in  any  manner  interfering  with,  injuring, 
or  destroying  any  of  the  property  of  said  Telegraph- 


12 


Cable  Company  engaged  in  or  used  for  the  purpose 
or  in  connection  with  interstate  commerce,  or  the 
transmission  of  messages  sent  by  the  Government  of 
the  United  States  or  any  of  the  officers  thereof,  and 
from  compelling  or  inducing,  or  attempting  to  compel 
or  induce  by  threats,  intimidation,  or  by  persuasion, 
force,  or  violence  any  of  the  employees  of  said  Tele- 
graph-Cable Company  to  refuse  or  fail  to  perform 
any  of  their  duties  as  employees  of  said  Telegraph- 
Cable  Company  in  connection  with  the  interstate 
business  or  commerce  of  such  company,  or  the  trans- 
mission of  messages  of  the  Government  of  the 
United  States  or  any  of  the  officials  thereof,  and  from 
compelling  or  inducing,  or  attempting  to  compel  or 
induce  by  threats  or  intimidation,  force,  or  violence 
any  of  the  employees  of  said  Telegraph-Cable  Com- 
pany who  are  employed  thereby  in  its  service  in  the 
conduct  of  interstate  business  or  in  the  transmission 
of  Government  messages,  to  leave  the  service  of  said 
Telegraph-Cable  Company,  and  from  preventing  any 
persons  whatever  by  threats,  intimidation,  force,  or 
violence  from  entering  the  service  of  said  Telegraph- 
Cable  Company,  and  doing  the  work  thereof  in  inter- 
state commerce  as  aforesaid,  and  from  doing  any 
act  whatever  in  furtherance  of  any  conspiracy  or 
combination  to  restrain  said  Telegraph-Cable  Com- 
pany in  the  free  and  unhindered  control,  handling, 
and  transmission  of  interstate  messages  or  messages 
of  the  Government  of  the  United  States  over  its 
lines,  and  from  ordering,  directing,  doing,  assisting, 


13 


or  abetting  in  any  manner  whatever  any  person  or 
persons  whatsoever  to  commit  any  or  either  of  the 
acts  aforesaid. 

May  it  please  your  honors  to  grant  your  orator  a 
temporary  injunction,  pending  final  hearing  of  this 
cause,  whereby  said  defendants,  and  each  and  every 
of  the  same,  their  confederates,  associates,  agents,  and 
servants,  and  all  other  individuals  and  associations 
who  may  now  or  hereafter  aid  or  abet  said  defendants, 
or  any  or  either  of  them,  in  doing  or  committing  the 
wrongs  hereinbefore  set  forth,  may  be  thereby  ordered 
and  commanded  to  refrain  and  be  thereby  restrained 
and  enjoined  as  hereinabove  prayed,  and  that  an 
order  may  be  entered  herein  that  said  restraining 
order  shall  be  in  force  and  binding  upon  said  local 
unions  aforesaid  and  all  officers  and  members  thereof 
from  and  after  the  service  of  said  order  upon  the 
president  or  any  one  of  the  officers  of  said  local 
unions  by  delivering  to  him  a copy  hereof,  and  that 
the  same  shall  be  binding  upon  each  and  all  of  the 
other  defendants  named  herein  from  and  after  service 
of  said  order  upon  them  and  each  of  them  by  deliver- 
ing a copy  or  by  reading  the  same  to  them  or  each  of 
them,  or  by  otherwise  bringing  the  same  to  their 
notice  and  knowledge;  and  that  such  order,  and  each 
and  every  part  thereof,  shall  be  severally  binding  upon 
all  of  said  defendants  and  upon  all  other  persons  from 
and  after  the  time  that  they  severally  have  knowledge 
of  the  entry  of  said  order.  And  that  your  orator 
may  have  such  other  and  further  relief  as  the  circum- 


14 


stances  may  require  and-  to  your  honors  may  seem 
meet. 

May  it  please  your  honors  to  grant  the  writ  of  sub- 
poena of  the  United  States  of  America,  issued  out  of 
and  under  the  seal  of  your  honorable  court,  directed 
to  the  said  International  Brotherhood  of  Electrical 
Workers,  local  Union  No.  9;  International  Brother- 
hood of  Electrical  Workers,  local  Union  No.  134, 
Martin  J.  Healy,  individually  and  as  President  of 
said  local  Union  No.  9;  Michael  J.  Boyle,  individu- 
ally and  as  president  of  said  local  Union  No.  134; 
William  J.  Sloan,  individually  and  as  business  agent 
of  said  local  Union  No.  9,  W.  N.  Harris,  E.  M.  Lamie, 
J.  J.  Elliott,  W.  Conrad,  E.  D.  Shanks,  G.  Florian, 
W.  Saunders,  B.  Warner,  W.  Sinclair,  S.  O.  Minor, 
A.  V.  Beckner,  F.  S.  Allen,  H.  Coghill,  M.  O’Day, 
J.  C.  Carroll,  jr.,  J.  Gaul,  Bert  Coghill,  and  Frank  H. 
Carroll,  commanding  them,  and  each  of  them  to 
appear  before  your  honorable  court  on  a day  certain 
to  be  fixed  by  the  court  and  then  and  there  stand  to 
and  abide  by  such  order,  judgment,  and  decree 
herein  as  to  your  honors  shall  seem  fit  and  proper. 

And  your  orator  will  ever  pray,  etc. 

James  H.  Wilkerson, 

United  States  Attorney , 

Northern  District  of  Illinois. 

George  W.  Wickersham, 

Attorney  General. 

James  A.  Fowler, 

Assistant  to  the  Attorney  General. 


15 


State  of  Illinois, 

County  of  Cook , 

, being  duly  sworn,  on  oath  deposes 

and  says  that  he  has  read  the  foregoing  bill  and  knows 
the  contents  thereof;  that  he  has  made  and  caused 
to  be  made  a most  thorough  and  exhaustive  examina- 
tion of  all  the  facts  and  other  matters  alleged  in  said 
bill  of  complaint  and  that  based  upon  such  investi- 
gation and  the  knowledge  thus  acquired,  he  says 
that  said  bill  of  complaint  and  all  of  its  contents  are 
true  to  the  best  of  his  knowledge,  information,  and 
belief. 

Subscribed  and  sworn  to  before  me  this day 

of , A.  D.  1913. 

, 

Notary  Public. 


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